What is an Environmental Product Declaration and how does it impact standard of care in the built environment?

As many people know, LEED v4 took a lot longer to be finalized than originally anticipated—largely due to political struggles involving key stakeholders and certain large enterprises. As many of my friends and colleagues know, I despise politics. Therefore, rather than get into all the muck, let’s dig into one of the more controversial subjects in LEED v4, and try to understand its impact on standard of care for the industry

What is an Environmental Product Declaration (EPD)? The always informative Stuart Kaplow has a great description at his blog, Green Building Law Update:

An environmental product declaration (EPD) is a method of quantifying the environmental impacts of a product. It is analogous to the nutritional label on a box of cereal. In the context of green building, EPDs will provide a way describing the environmental impact of a building material or product.

EPDs articulate the conclusions of a life cycle assessment. The aim of an EPD is to facilitate the comparison of the range of environmental effects attributable to a product in order to provide a sound basis for making informed decisions.

Life cycle assessment is widely accepted to encompass 5 stages: raw material acquisition, manufacturing, transportation, use, and end of life.

In other words, an EPD is a third-party assessment of certain material characteristics based upon objective criteria. If manufacturers produce an EPD for a given product, it offers design and construction professionals handy insight into the environmental impact of that product.

How EPDs affect Standard of Care

When we talk about environmental impact, an important part of the equation also involves impact on human health—since we are also part of the environment. One of the components to an EPD is toxicity. This is where things start to get really interesting. There are multiple approaches to assessing toxicity, including certain ISO standards that have been adopted by various European countries. In particular, ISO 14025 is referenced by the USGBC. Unfortunately, that standard was last updated in 2006, making it somewhat out of date in the fast-paced world of high performance design and construction.

Among the loudest critics of the LEED v4 Materials & Resources credits related to EPDs is Perkins+Will architect Douglas Pierce, who authored a White paper, “LEED V4 Should Lead On Material Health Transparency By Accepting Only Environmental Product Declarations (EPDs) That Comply With the Federal Trade Commission’s (FTC) Truth in Advertising Law”. Pierce highlights that EPDs and their use in LEED V4 “have a large loophole related to toxicity”. The White paper argues that toxicity must be detailed or risk violating the Federal Trade Commission Green Guides.

In other words, the standards for defining toxicity related to EPDs still have some work left. The difficulty here is immediately apparent, as architects like Pierce may in effect be forced to make legal interpretations. As Kaplow explains:

The White paper is legally not correct, .. but who would seek legal advice from architects (even a well respected architecture firm like Perkins+Will)? However, the White paper is useful in identifying the shortcomings of EPDs and in particular ISO based EPDs.

Will we need to include legal counsel as part of the design charettes in the Integrative Project Design process? (I actually do think that that is a very wise suggestion.)

Should attorneys be reviewing BIM files and specifications? After all, those do constitute “contract documents” and who better than an attorney to evaluate the merits of a contract? (I think that is a horrible idea – especially at the hourly rates most attorneys charge…)

Moving Forward, to a healthier built environment

Regardless, in my opinion, the best aspect of the whole discussion around objective third-party standards related to Environmental Product Disclosures, is that we are even having the discussion in the first place.

Only through intelligent discourse, backed by evidence, can we move forward to improving both the environmental and health impacts of the products we use to design and construct the buildings in which we live, work, play and come together.

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Published by Brian L. Hill

As Director of Consulting Services for Xpera Group, Brian L. Hill connects clients to the diverse range of experts, technical specialists, tools and other resources that the firm has to offer in order to solve complex building performance issues. He is also the editor and publisher of AECforensics.com, which dissects the latest news and information impacting quality and risk management in the built environment.
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